SZTAC 76/2021/IR; 2018/1696/IW
Social insurance payments paid abroad through the company’s head office and any technical or administrative consulting fees paid through it, as well as tax deducted on such amounts, may not represent income for the head office but rather for independent parties, which are the social insurance funds and companies that provided those services and consultations.
Background
On Tuesday, 22/09/1442 AH corresponding to 04/05/2021, the First Appellate Circuit of Income Tax Violations and Disputes constituted according to Saudi Arabia Royal Order No. 65474/1439 dated 23/12/1439 AH, held at its headquarters in Riyadh, to consider the appeal brought by ..... Company on 06/06/1438 AH, to challenge the Second Circuit of the First Instance Tax Zakat Objection Committee in Riyadh decision No. (7) of 1438 issued in the tax assessment from 2005-2009 case filed by the appellant against GAZT, in which the Preliminary Decision determined that:
First: To admit in form the objection to the tax assessment from 2005-2009 filed by ………………………. Company, in accordance with the recitals in this decision.
Second: On merits: